LAW OFFICES

HEARNE&BENDICK LLC
ATTORNEYS AT LAW
230 SOUTH BEMISTON, SUITE 770
ST. LOUIS, MISSOURI 63105

MATTHEW H. HEARNE (Licensed in Missouri)

BRIAN B. BENDICK (Licensed in Missouri and Illinois)

TELEPHONE (314) 863-0200

TELEFAX (314) 863-4247

December 2, 2014

St. Louis County Police Chief Jon Belmar

7900 Forsyth Blvd.
St. Louis, Mo. 63105
Dear Chief Belmar:
This letter is to inform you that I have been retained by several property owners
in Ferguson and the Oath Keepers, who are a collection of current and former police
officers, firefighters, paramedics, EMTs and military personal, to represent them in all
matters pertaining to their assistance in the City of Ferguson.
It has come to our attention that several members of the Oath Keepers have been
told that they may not assist local residents, property owners and tenants with the
protection of their lives and property. Specifically, our members have been told by
several police officers that to remain in Ferguson they would need to become licensed
security guards.
Please understand that the Oath Keepers are unpaid volunteers and have been
invited at the specific request of the business owners and are their guests. As Greg
Hildebrand, a resident of Ferguson stated, The Oath Keepers were a valuable presence
willing to help when others wouldnt. When the riots started they were on my roof with
fire extinguishers and buckets ready to put out fires. They were a huge help.
A review of the applicable statutes and regulations makes clear that the Oath
Keepers do not fall under the provisions of St. Louis County Code Section 701.115 as
suggested by your officers. Section 701.115 only applies to Security Officers as defined

by the St. Louis County Code. As defined by the St. Louis County Code and the St.
Louis County Police Manual a Security Officer is a paid professional that has certain
powers and authority including the power to make arrests, detentions and conduct
searches and seizures and as such falls under the regulations of the St Louis County
Police Department. As I stated earlier, the Oath Keepers are unpaid, guests of the
property owners as such they do not have the power to make arrests and are not subject
to the rules and regulations of Security Officers.
To assert that the property owners of Ferguson do not have the right to invite the
Oath Keepers to assist them would be tantamount to telling an individual that they do
not have the right to assist a neighbor in need.
Additionally the property owners and Oath Keepers have numerous other
Rights guaranteed by the United States Constitution including the right to freely
assemble which may not be restricted by any County Ordinance or State Statute.
If you have any questions or comments, please do not hesitate to contact me.
Sincerely,
Matthew H. Hearne
mhearne@hb-law.com